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CRM 2000 - 2500

2137. Jury Instruction -- Elements Of 18 U.S.C. § 1956(a)(2)(B)(ii)

There are three elements to Count __ of this indictment which the government must prove:

FIRST, the defendant must knowingly transport, transmit, or transfer, or attempt to transport, transmit, or transfer [a] monetary instrument[s] or funds

SECOND, from a place in the United States to or through a place outside the United States or to a place in the United States from or through a place outside the United States;

THIRD, the defendant must know that the monetary instrument[s] or funds involved in the transportation, transmission, or transfer, or attempted transportation, transmission, or transfer, represent the proceeds of some form of unlawful activity;

FOURTH, the defendant must know that the transportation, transmission, or transfer, or attempted transportation, transmission, or transfer, is designed, in whole or in part, to avoid a transaction reporting requirement under state or federal law.

Title 18, U.S.C., § 1956(a)(2)(B)(ii)

Granted

Denied